GHG Reporting Program: Subpart RR, Geologic Sequestration of ...

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Greenhouse Gas Reporting Program Subpart RR: Geologic Sequestration of Carbon Dioxide

This training is provided solely for informational purposes. It does not provide legal advice, have legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits in regard to any person.

Updated 2/8/12

For a copy of these slides, visit: http://www.epa.gov/climatechange/emissions/training.html

Outline

• Overview and Schedule

• Electronic Greenhouse Gas Reporting Tool (e-GGRT)

• Summary of Subpart RR requirements – Applicability

– Submissions due prior to annual reporting

Overview of Subparts RR and UU

• EPA has finalized greenhouse gas (GHG) reporting mechanisms for facilities that conduct geologic sequestration (subpart RR) and all other facilities that inject carbon dioxide (CO2) underground for enhanced oil and gas recovery or any other purpose (subpart UU). – Proposal signed on March 22, 2010. – Final rule signed on November 22, 2010.

• This rule is complementary to and builds on EPA’s Underground Injection Control (UIC) permit requirements

• On November 9, 2011 EPA finalized Technical Corrections, Clarifying and Other Amendments to seven subparts, including RR and UU.

Geologic Sequestration of Carbon Dioxide (Subpart RR)

• Facilities that conduct geologic sequestration by injecting CO2 for long-term containment in subsurface geologic formations are required to: – Report basic information on CO2 received for injection.

– Develop and implement an EPA-approved site-specific monitoring, reporting, and verification (MRV) plan.

– Report the amount of CO2 geologically sequestered using a mass balance approach and annual monitoring activities.

• All facilities that hold a UIC Class VI permit must report under Subpart RR.

Geologic Sequestration of Carbon Dioxide (Subpart RR)

• Facilities that conduct enhanced oil and gas recovery are not required to report geologic sequestration under Subpart RR unless

1. the owner or operator chooses to opt-in to Subpart RR or,

2. the facility holds a UIC Class VI permit for the well or group of wells used to enhance oil and gas recovery

• R&D projects will be granted an exemption from Subpart RR

provided they meet the eligibility requirements

Injection of Carbon Dioxide (Subpart UU)

• Under Subpart UU, all facilities that inject CO2 underground for purposes besides geologic sequestration, such as for enhanced oil and gas recovery or any other purpose, are required to report basic information on CO2 received for injection.

• Geologic sequestration R&D projects that receive an exemption from Subpart RR are required to report under Subpart UU.

Subpart RR Submissions

• Registration and Certificate of Representation (COR) for each facility

• One of the following: – Proposed Monitoring, Reporting, and Verification (MRV)

plan – MRV plan extension request – R&D project exemption request

• Annual reports (starting in 2012 for data collected in 2011)

Use e-GGRT for facility registration and

submissions 8

Subpart RR Submissions Schedule

1. Register your facility and submit your Certificate of Representation 60 days before making a submission under Subpart RR.

2. Submit a proposed MRV plan, MRV plan submission extension request (up to 180 day extension), or R&D project exemption request through e-GGRT by the following deadlines:

Facility issued UIC permit on or before December 31, 2010

• Submit MRV plan, MRV plan extension request, or R&D project exemption request by June 30, 2011

Facility issued UIC permit on or after January 1, 2011

• Submit MRV plan, MRV plan extension request, or R&D project exemption request within 180 days of receiving final UIC permit

Electronic Greenhouse Gas Reporting Tool (e-GGRT)

For more information

On the GHG Reporting Program: http://www.epa.gov/climate/climatechange/emissions/ghgrulemaking.html On the GHG Data System: http://www.ccdsupport.com Contact Us: http://www.epa.gov/climate/climatechange/emissions/ghgrule_contactus.htm

On ‘Contact Us’ page select e-GGRT for data system questions

Overview

• Purpose of this portion of the webinar • About e-GGRT • e-GGRT user registration • e-GGRT facility/supplier registration • Registering Designated Representatives (DR),

Alternate Designated Representatives (ADR) and Agents

• Questions & Answers

About Today’s Webinar

• Today, we will explain how reporters will register in e-GGRT to submit the Certificate of Representation

• We will NOT discuss how facilities and suppliers will use e-GGRT to create and submit annual GHG reports – This will be discussed in future webinars

• We will not be discussing … – Applicability Determinations

– GHG emission calculations

– Proposed rulemakings

• Web-based system

– Will guide reporters through data entry and submission

– Built-in calculations

• Reporters may choose to format their annual GHG report according to the e-GGRT XML schema

– These reporters must meet the same registration and submission deadlines as all other reporters

About e-GGRT

• All data is submitted to EPA electronically in e-GGRT – Except the one-time Electronic Signature Agreement

(ESA) which is submitted on paper

• e-GGRT supports reporting required under Part 98 – e-GGRT does NOT support record keeping

requirements under Part 98

About e-GGRT

• System Requirements – Internet Explorer 7+ or Firefox 3+ – Javascript enabled in the browser – Transport Layer Security (TLS)

enabled in the browser – PDF reader (e.g. Adobe Reader) – Access to printer (for Electronic

Signature Agreement) – Access to the Internet – Personal (private) email account

• E-GGRT performs a browser test and

will redirect to these pages if you fail

• E-GGRT enforces a ten-minute inactivity timeout.

User Registration: Getting Started

• Information you will need includes: – Name – Mailing address – Email address

• If you are an EPA Central Data Exchange (CDX) user: – CDX User Name and Password

• If you are a CAMD Business System (CBS) reporter: – CBS User Name and Password

Registration: Overview

New e-GGRT Users

USER REGISTRATION

Enter Basic Info to Become an

e-GGRT USER

EPA APPROVES Electronic Signature Agreement (ESA)

FACILITY AND SUPPLIER

REGISTRATION

APPOINT DESIGNATED

REPRESENTATIVE (DR)

SET UP AGENT(S)

SIGN AND SUBMIT Certificate of

Representation (COR)

SIGN AND SUBMIT Notice of

Delegation (NOD)

User Registration: Login Page

As a new e-GGRT user you will start at the e-GGRT login page:

https://ghgreporting.epa.gov

Context sensitive help on every page

If you have a CDX account then log in with your CDX credentials here

Otherwise, click the green NEW USER REGISTRATION button

User Registration: On-Screen Directions

On-screen directions will guide you through the user registration process. Most e-GGRT pages allow you to freely navigate and come back later to complete them. New user registration, however, requires you to complete the four steps in one session.

User Registration: Your User Profile

Please note the following when filling out your profile: Profile information will be used on the Certificate of Representation (if you are a DR or ADR) or Notice of Delegation (if you are an Agent)

User Registration: On-Screen Directions

Throughout the registration process on-screen directions and validation messages will provide help

The Secret Question and Answer are used if you need to reset your password. Store this information securely.

User Registration: Challenge Questions

E-GGRT will use Challenge Questions and Answers later to support Electronic Signatures so keep them stored securely.

User Registration: Electronic Signature Agreement

On this final page you can print out your Electronic Signature Agreement. You can also save a copy as a PDF file.

User Registration: Electronic Signature Agreement

John Metropolis 123 Industrial Way Beverley Hills, CA 90210 e-GGRT Help Desk

8301 Greensboro Drive Mail Stop E-11-2 McLean, VA 22102

Please allow time to mail your Electronic Signature Agreement to EPA

You MUST sign and date your ESA

User Registration: Electronic Signature Agreement Approved!

Notifications from e-GGRT will be sent to the email address in your user profile. Make sure your email accepts mail from eggrt@ccdsupport.com For questions about the GHG Reporting Program or e-GGRT, contact EPA at GHGMRR@epa.gov

Registering A Facility

Click “Register A Facility” from your e-GGRT Home Page

If you are a CBS user and have linked your CBS and e-GGRT accounts, your CBS facilities will be listed here.

Log-In to e-GGRT at: https://ghgreporting.epa.gov

Facility Registration A “subway map” will show you where you are in the Facility setup process

e-GGRT will help you SEARCH through EPA’s Facility Registry System for your facility.

Facilities that have already been registered will be labeled “Claimed”

Facility Registration

List the owners and operators of the facility or supplier here. Click “ADD” to list more.

Facility Registration

You can appoint yourself as DR or someone else. EPA will review all appointments

Enter the ADR’s info here, if applicable. An ADR can also be added at a later time but must be approved by the DR

Grey boxes in e-GGRT provide explanatory text. You may also click HELP at any time for more info.

The email will be used by e-GGRT to invite the DR appointee to accept their role.

Appointments and Invitations: DR & ADR

APPOINT

DR or ADR

EPA APPROVES &

E-GGRT sends email

APPOINTEE

Receives email Uses CODE

To ACCEPT Role

APPOINTEE

Signs Certificate of Representation

Appointments and Invitations: Agent(s)

SET UP AGENT(S)

EPA APPROVES &

E-GGRT sends email

APPOINTEE

RECEIVES email USES code

To ACCEPT Role

DELEGATOR

Signs Notice of Delegation

DELEGATOR

RECEIVES email REVIEWS Agent

Delegation

Using an Invitation Code

After an APPOINTEE receives an email invitation for a ROLE, he or she can log into e-GGRT and paste the invitation code into this box.

Home Page lists facilities and role

Accepting the Appointment

ANYREPORTER 123 Main Street ANYTOWN, USA, ANYZIP

Uncle JOE 202-123-4567 Joe.Uncle@mail.com

Certificate of Representation

Carefully review the Certification Statements. These Certification Statements can also be found in Section 98.4 of the Rule

Facility Summary

Subpart RR Start Page

e-GGRT Support

• E-GGRT Help Desk will be able to answer questions and provide support to e-GGRT users

• Telephone: 1-877-444-1188

• Email: GHGREPORTING@epa.gov [e-GGRT] GHGMRR@epa.gov [RULE]

• URLs: www.ccdsupport.com [Help]

https://ghgreporting.epa.gov [e-GGRT]

Before you Contact the e-GGRT Help Desk

• Can I login to e-GGRT using my CAMD Business System user name and password? No. You can, however, use your CDX user name and password to login to e-GGRT.

• How do I reset my CDX password? If you have not yet logged into e-GGRT and you need to reset your CDX password, go to https://cdx.epa.gov/SSL/cdx/login.asp. The "Forgot Password" link on the e-GGRT home page will not work unless you have successfully logged into e-GGRT at least once.

• Can I reuse my CAMD Business System Electronic Signature Agreement, or do I need to mail in a new one? If you already have an Electronic Signature Agreement on file with the CAMD Business System, e-GGRT can reuse it if you provide your CAMD Business System user name and password when requested during user registration, and no additional Electronic Signature Agreement is needed

e-GGRT Help Site www.ccdsupport.com

Additional Information

Questions?

Subpart RR Topics for Today

• Applicability – Who is subject to Subpart RR?

• Submission due prior to annual reporting – R&D Project Exemption Request OR

– Proposed Monitoring, Reporting, and Verification (MRV) Plan

Applicability: Which Facilities Must Report Under Subpart RR?

• Subpart RR source category includes: – Any well or group of wells that inject a CO2 stream for long-

term containment in subsurface geologic formations – All wells permitted as UIC Class VI wells

• Facilities that conduct enhanced oil and gas recovery are not required to report geologic sequestration under Subpart RR unless

1. the owner or operator chooses to opt-in to Subpart RR or, 2. the facility holds a UIC Class VI permit for the well or

group of wells used to enhance oil and gas recovery Facilities that report under Subpart RR are not

required to report under Subpart UU 43

R&D Project Exemption Request Process Overview

No: Reporter must submit a Subpart RR MRV plan

Reporter submits annual report under Subpart UU

Yes: Reporter is subject to Subpart UU and collects basic info on CO2 received

EPA decision: Does the project meet the definition of R&D project?

EPA reviews request (iterative with reporter)

Reporter submits R&D project exemption request via e-GGRT

Reporter registers facility and submits COR

Note: EPA decision may be appealed by an interested person to EPA Environmental Appeals Board

R&D Exemption Request Submission Page (example)

Web form for R&D project exemption requests.

R&D Project Exemption

• R&D projects will be granted an exemption from Subpart RR provided they meet the eligibility requirements

• A project is eligible for the exemption if it meets the Subpart RR definition of R&D project: – a project for the purpose of investigating practices, monitoring

techniques, or injection verification, or engaging in other applied research, that will enable safe and effective long-term containment of a CO2 stream in subsurface geologic formations, including research and short duration CO2 injection tests conducted as a precursor to long-term storage

• R&D project exemption requests must be submitted using the webform that is provided in e-GGRT.

• NOTE: Projects receiving a Subpart RR R&D exemption report under Subpart UU.

R&D Project Exemption Request Content

• A submission in support of an exemption as an R&D project must contain the following information: – The planned duration of CO2 injection for the project – The planned annual CO2 injection volumes during this time

period – The research purposes of the project – The source and type of funding for the project – The class and duration of UIC permit or, for an offshore

facility not subject to the Safe Drinking Water Act, a description of the legal instrument authorizing geologic sequestration

R&D Project Exemption Request Content

• The research purpose in the reporter’s request provides a key piece of information on which EPA will base its decision to grant or deny the R&D exemption request. – EPA encourages reporters applying for an exemption to provide

detailed information about the research purpose. – Examples:

• Description of monitoring technologies tested at the GS project • Citations for published research at the site, if they exist • How the research is moving the science of monitoring GS sites forward • Description of the short-term injectivity testing, if this is the purpose of

the exemption request

• Other aspects of the submission also provide relevant information on the project – For example, the estimated duration the project will aid in

determining the length of time of the exemption

MRV Plan Review Process Overview

Notes: (1)EPA decision may be appealed by an interested person to EPA Environmental Appeals Board (2) MRV plan resubmittals follow the same process

Reporter adds data to Subpart RR annual report on the amount of CO2 that is sequestered and annual monitoring

If approved, Reporter implements MRV plan

EPA Decision

EPA technical review of the MRV plan (iterative w/ reporter)

EPA reviews MRV plan for completeness (if incomplete, reporter must resubmit)

Reporter submits MRV plan via e-GGRT

Reporter registers facility and submits COR

MRV Plan Submission Page (example)

Upload MRV plan as a single zip file, submit, and certify.

MRV Plan Submission Extension Request (example)

Contents of MRV Plan

1. Delineation of the maximum monitoring area (MMA) and active monitoring areas (AMAs)

2. Identification of potential surface leakage for pathways in the MMA

3. A strategy for detecting and quantifying surface leakage of CO2

4. A strategy for establishing the expected baseline for monitoring CO2 surface leakage

5. Site-specific variables for the mass balance equation 6. Well identification number(s) 7. Proposed date to begin collecting data for calculating total

amount sequestered (Equations RR-11 and RR-12) – Date must be after expected baselines are established and the leakage

detection and quantification strategy is implemented in the initial AMA

1. Monitoring Areas

• Maximum monitoring area is the area expected to contain the free phase CO2 plume until the CO2 plume has stabilized plus an all-around buffer zone of at least one-half mile

• Active monitoring area is the area that will be monitored over a specific time interval from the first year of the period (n) to the last year in the period (t). – This allows operators to phase in monitoring so that during

any given time interval, only that part of the MMA in which leakage might occur needs to be monitored.

• MRV plan must identify the likelihood, magnitude, and timing of potential leakage from each pathway

• Example pathways: – Wells

• Injection well(s) • Monitoring wells • Active/abandoned oil and gas wells

– Faults, fractures, and bedding plane partings – Confining zone competency, extent and dip

2. Potential Leakage Pathways

3. Surface Leakage Detection, Verification, and Quantification Strategy

• Detection – Leakage detection systems may include continuous measurements

and/or regular periodic surveys (e.g. water chemistry, airborne surveys, mechanical integrity testing)

– Detection capability should be described in the MRV plan • Verification

– Leakage verification allows reporter to confirm the location and source of leakage that has been detected

– MRV plan may describe the methods and criteria for determining how an anomalous reading or condition will be evaluated to determine if it represents a leak, and to verify the location and source of the leak

• Quantification – MRV plan must include a discussion of how leaks will be

quantified once they are detected and verified – Multiple monitoring technologies and quantification techniques

can address different leakage pathways and leakage calculation methods 55

4. Strategy for establishing the expected baseline

• Expected baselines allow the reporter to discern whether the results of monitoring are attributable to leakage of injected CO2

• Parameters may be environmental such as subsurface pressure, soil flux rates, etc., or operational, such as the injection pressure and the annular pressure in the well

• The MRV plan should describe how the baselines will be determined and how they could be used to detect monitoring anomalies

5. Entrained CO2 in produced fluids

• Fluids produced at GS facilities may contain CO2 that is not captured in the gas phase CO2 measurement downstream of the gas-liquid separator – Dissolved gas in the oil or water phase of the produced fluids – Dissolved in water extracted from the injection zone

• Equation RR-9 describes the mass balance of CO2 at the gas-liquid separator including amount of CO2 in the produced oil and water – In the MRV plan, the reporter should estimate the

percentage of entrained CO2 in produced oil or other fluid – For example, this can be determined using industry standard

laboratory analyses

When Are Annual Reports Due?

• Subpart RR – Submit annual reports to EPA in 2012 reporting basic

information on CO2 received in 2011.

– Once EPA-approved MRV plan is implemented, add data to annual reports on the amount of CO2 that is geologically sequestered based on mass balance approach and annual monitoring activities.

• Subpart UU – Submit annual reports to EPA in 2012 reporting basic

information on CO2 received in 2011.

For More Information

• Subpart RR Information and Help – http://www.epa.gov/climatechange/emissions/subpart/rr.html – Email: GHGMRR@epa.gov

• e-GGRT Information and Help

– http://www.ccdsupport.com – Email: GHGreporting@epa.gov

• GHG Reporting Program Information:

– http://www.epa.gov/climate/climatechange/emissions/ghgrulemaking.html

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